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US Export Controls Compliance Practices Benchmarks for Higher Education

US Export Controls Compliance Practices Benchmarks for Higher Education

21 colleges participated in this study which looks closely at how colleges and universities are complying with U.S. export control regulations and related strictures.  The study presents detailed data on staffing, budgets, spending on information and conferences, use of government and private sector resources and consultants, legal spending and other facets of the efforts by colleges in the United States to comply with U.S, export control regulations that seek to control the outflow of critical technologies, particularly those with a military or dual use application.    Among other issues covered:  experience of hacking attacks on data subject to export controls, controls on foreign students and scholars, restrictions on information dissemination, interface with the US government export control bureaucracy, development of risk assessment reports and much more.


THE QUESTIONNAIRE
PARTICIPANTS LIST
Characteristics of the Sample
SUMMARY OF MAIN FINDINGS
Characteristics of the Sample
How much do Your Faculty and Researchers Know about Export Controls?
What Percentage of Research Efforts is Subject to Export Controls?
Pervasiveness of Hacking Attacks on Data Subject to Export Controls
Staff Time Devoted to Export Control Compliance
Use of Outside Attorneys for Export Control Compliance Issues
Export Control Compliance Training Practices
Use of a Manual or Workbook on Export Control Compliance
Penalties for Failing to Complete Export Control Compliance Training
Participation in the CITI Initiative
Making Training Videos
Use of Videos from Vendors
Use of Government-Made Videos
Developing Webinars for Export Control Compliance Training
Use of Webinars from a Vendor
Attendance at Conferences about Export Controls
Supplying Export Compliance Training to New Faculty, Postdocs, Graduate Students and Undergraduates
Spending on Training Vehicles for Export Control Compliance
Restrictions Placed on Foreign Nationals
Use of Periodic Risk Assessment Reports
Role Played in Export Control Compliance by the Office of Sponsored Research.
Screening of Foreign Travel, Sponsored Research, Conference Presentations and other Activities
Number of Technology Control Plans Filed in the Past Three Years
Experience with the Commerce Department’s Bureau of Industry & Security
Number of Export Control Licenses Applied for in the Past Year
Institutions with Exemplary Export Control Compliance Procedures
Main Information Sources for Export Compliance
Researcher Knowledge of Export Controls
Table 1.1 About how pervasive is knowledge of export controls in the faculties or research employees with whom you traditionally deal?
Table 1.2 About how pervasive is knowledge of export controls in the faculties or research employees with whom you traditionally deal? Broken out by Public/Private Status
Table 1.3 About how pervasive is knowledge of export controls in the faculties or research employees with whom you traditionally deal? Broken out by Carnegie class or type of college
Table 1.4 About how pervasive is knowledge of export controls in the faculties or research employees with whom you traditionally deal? Broken out by Annual Tuition.
Table 1.5 About how pervasive is knowledge of export controls in the faculties or research employees with whom you traditionally deal? Broken out by Enrolment
Table 2.1 If your organization is a college, university or other non-profit research organization, about what percentage of the research done by your institution would you say falls under the "Fundamental Research" exclusion provision of US export control laws?
Table 2.2 If your organization is a college, university or other non-profit research organization, about what percentage of the research done by your institution would you say falls under the "Fundamental Research" exclusion provision of US export control laws? Broken out by Public/Private Status
Table 2.3 If your organization is a college, university or other non-profit research organization, about what percentage of the research done by your institution would you say falls under the "Fundamental Research" exclusion provision of US export control laws? Broken out by Carnegie class or type of college
Table 2.4 If your organization is a college, university or other non-profit research organization, about what percentage of the research done by your institution would you say falls under the "Fundamental Research" exclusion provision of US export control laws? Broken out by Annual Tuition.
Table 2.5 If your organization is a college, university or other non-profit research organization, about what percentage of the research done by your institution would you say falls under the "Fundamental Research" exclusion provision of US export control laws? Broken out by Enrolment
Data Protection
Table 3.1 To the best of your knowledge, has your institution experienced hacking attacks on data subject to export controls?
Table 3.2 To the best of your knowledge, has your institution experienced hacking attacks on data subject to export controls? Broken out by Public/Private Status
Table 3.3 To the best of your knowledge, has your institution experienced hacking attacks on data subject to export controls? Broken out by Carnegie class or type of college
Table 3.4 To the best of your knowledge, has your institution experienced hacking attacks on data subject to export controls? Broken out by Annual Tuition
Table 3.5 To the best of your knowledge, has your institution experienced hacking attacks on data subject to export controls? Broken out by Enrolment
Table 4.1 If your institution has experienced hacking attacks on data subject to export controls, how would you characterize the nature of such attacks?
Table 4.2 If your institution has experienced hacking attacks on data subject to export controls, how would you characterize the nature of such attacks? Broken out by Public/Private Status
Table 4.3 If your institution has experienced hacking attacks on data subject to export controls, how would you characterize the nature of such attacks? Broken out by Carnegie class or type of college
Table 4.4 If your institution has experienced hacking attacks on data subject to export controls, how would you characterize the nature of such attacks? Broken out by Annual Tuition
Table 4.5 If your institution has experienced hacking attacks on data subject to export controls, how would you characterize the nature of such attacks? Broken out by Enrolment
USES OF STAFF TIME
Table 5.1 How much institutional staff time would you say that your office expends on complying with export control regulations? (One person working full time would work approximately 1850 hours per year in most institutions)
Table 5.2 How much institutional staff time would you say that your office expends on complying with export control regulations? (One person working full time would work approximately 1850 hours per year in most institutions) Broken out by Public/Private Status
Table 5.3 How much institutional staff time would you say that your office expends on complying with export control regulations? (One person working full time would work approximately 1850 hours per year in most institutions) Broken out by Carnegie class or type of college
Table 5.4 How much institutional staff time would you say that your office expends on complying with export control regulations? (One person working full time would work approximately 1850 hours per year in most institutions) Broken out by Annual Tuition
Table 5.5 How much institutional staff time would you say that your office expends on complying with export control regulations? (One person working full time would work approximately 1850 hours per year in most institutions) Broken out by Enrolment
Table 6.1 In full time equivalent staff, how many individuals are largely dedicated to export control compliance responsibilities in your organization?
Table 6.2 In full time equivalent staff, how many individuals are largely dedicated to export control compliance responsibilities in your organization? Broken out by Public/Private Status
Table 6.3 In full time equivalent staff, how many individuals are largely dedicated to export control compliance responsibilities in your organization? Broken out by Carnegie class or type of college
Table 6.4 In full time equivalent staff, how many individuals are largely dedicated to export control compliance responsibilities in your organization? Broken out by Annual Tuition
Table 6.5 In full time equivalent staff, how many individuals are largely dedicated to export control compliance responsibilities in your organization? Broken out by Enrolment
LEGAL ASSISTANCE COSTS
Table 7.1 Has the office in charge of export control compliance used outside attorneys within the past year for any issue related to export controls?
Table 7.2 Has the office in charge of export control compliance used outside attorneys within the past year for any issue related to export controls? Broken out by Public/Private Status
Table 7.3 Has the office in charge of export control compliance used outside attorneys within the past year for any issue related to export controls? Broken out by Carnegie class or type of college
Table 7.4 Has the office in charge of export control compliance used outside attorneys within the past year for any issue related to export controls? Broken out by Annual Tuition
Table 7.5 Has the office in charge of export control compliance used outside attorneys within the past year for any issue related to export controls? Broken out by Enrolment
Table 8.1 If so, how many hours of outside legal time did this department use in the past year?
Table 8.2 If so, how many hours of outside legal time did this department use in the past year? Broken out by Public/Private Status
Table 8.3 If so, how many hours of outside legal time did this department use in the past year? Broken out by Carnegie class or type of college
Table 8.4 If so, how many hours of outside legal time did this department use in the past year? Broken out by Annual Tuition
Table 8.5 If so, how many hours of outside legal time did this department use in the past year? Broken out by Enrolment
Table 9.1 What was the average cost per hour for the outside legal assistance required by the department handling export controls? (all figures in $ US)
Table 9.2 What was the average cost per hour for the outside legal assistance required by the department handling export controls? (all figures in $ US) Broken out by Public/Private Status
Table 9.3 What was the average cost per hour for the outside legal assistance required by the department handling export controls? (all figures in $ US) Broken out by Carnegie class or type of college
Table 9.4 What was the average cost per hour for the outside legal assistance required by the department handling export controls? (all figures in $ US) Broken out by Annual Tuition
Table 9.5 What was the average cost per hour for the outside legal assistance required by the department handling export controls? (all figures in $ US) Broken out by Enrolment
TRAINING IN EXPORT CONTROL COMPLIANCE
Are seminars or other forms of training in export control compliance required of some faculty or employees and if so, which faculty, and how extensive is the required training?
Table 10.2 Do you have a manual or workbook that describes effective export control compliance? Broken out by Public/Private Status
Table 10.3 Do you have a manual or workbook that describes effective export control compliance? Broken out by Carnegie class or type of college
Table 10.4 Do you have a manual or workbook that describes effective export control compliance? Broken out by Annual Tuition
Table 10.5 Do you have a manual or workbook that describes effective export control compliance? Broken out by Enrolment
How is this manual or workbook distributed or otherwise made known to employees, faculty, postdocs, researchers and others in your organization who need to know?
If export control compliance training is required, what is the penalty for failure to do it?
Table 11.1 Does your institution participate in the Collaborative Institutional Training Initiative (CITI) for export control compliance training?
Table 11.2 Does your institution participate in the Collaborative Institutional Training Initiative (CITI) for export control compliance training? Broken out by Public/Private Status 49
Table 11.3 Does your institution participate in the Collaborative Institutional Training Initiative (CITI) for export control compliance training? Broken out by Carnegie class or type of college
Table 11.4 Does your institution participate in the Collaborative Institutional Training Initiative (CITI) for export control compliance training? Broken out by Annual Tuition
Table 11.5 Does your institution participate in the Collaborative Institutional Training Initiative (CITI) for export control compliance training? Broken out by Enrolment
Table 12 Which of the following has your organization done in terms of making training videos on export control compliance available to those in your organization?
Table 12.1.1 Made your own training video?
Table 12.1.2 Made your own training video? Broken out by Public/Private Status
Table 12.1.3 Made your own training video? Broken out by Carnegie class or type of college
Table 12.1.4 Made your own training video? Broken out by Annual Tuition
Table 12.1.5 Made your own training video? Broken out by Enrolment
Table 12.2.1 Provided a video from a consultant or other vendor?
Table 12.2.2 Provided a video from a consultant or other vendor? Broken out by Public/Private Status
Table 12.2.3 Provided a Video from a Consultant or other vendor? Broken out by Carnegie class or type of college
Table 12.2.4 Provided a video from a consultant or other vendor? Broken out by Annual Tuition
Table 12.2.5 Provided a video from a consultant or other vendor? Broken out by Enrolment
Table 12.3.1 Made available government videos?
Table 12.3.2 Made available government videos? Broken out by Public/Private Status
Table 12.3.3 Made available government videos? Broken out by Carnegie class or type of college
Table 12.3.4 Made available government videos? Broken out by Annual Tuition
Table 12.3.5 Made available government videos? Broken out by Enrolment
Table 12.4.1 Provide your own webinar?
Table 12.4.2 Provide your own webinar? Broken out by Public/Private Status
Table 12.4.3 Provide your own webinar? Broken out by Carnegie class or type of college
Table 12.4.4 Provide your own webinar? Broken out by Annual Tuition
Table 12.4.5 Provide your own webinar? Broken out by Enrolment
Table 12.5.1 Make available a webinar from a vendor?
Table 12.5.2 Make available a webinar from a vendor? Broken out by Public/Private Status
Table 12.5.3 Make available a webinar from a vendor? Broken out by Carnegie class or type of college
Table 12.5.4 Make available a webinar from a vendor? Broken out by Annual Tuition
Table 12.5.5 Make available a webinar from a vendor? Broken out by Enrolment
Table 12.6.1 Pay for export control conference attendance for selected employees?
Table 12.6.2 Pay for export control conference attendance for selected employees? Broken out by Public/Private Status
Table 12.6.3 Pay for export control conference attendance for selected employees? Broken out by Carnegie class or type of college
Table 12.6.4 Pay for export control conference attendance for selected employees? Broken out by Annual Tuition, $
Table 12.6.5 Pay for export control conference attendance for selected employees? Broken out by Enrolment
Table 13 Does your organization provide export control compliance training in any of the following settings? (check all that apply)
Table 13.1.1 Does your organization provide export control compliance training in Orientation for New Faculty in Select Disciplines?
Table 13.1.2 Does your organization provide export control compliance training in Orientation for New Faculty in Select Disciplines? Broken out by Public/Private Status
Table 13.1.3 Does your organization provide export control compliance training in Orientation for New Faculty in Select Disciplines? Broken out by Carnegie class or type of college
Table 13.1.4 Does your organization provide export control compliance training in Orientation for New Faculty in Select Disciplines? Broken out by Annual Tuition
Table 13.1.5 Does your organization provide export control compliance training in Orientation for New Faculty in Select Disciplines? Broken out by Enrolment
Table 13.2.1 Does your organization provide export control compliance training in Orientation for Postdocs in Select Disciplines?
Table 13.2.2 Does your organization provide export control compliance training in Orientation for Postdocs in Select Disciplines? Broken out by Public/Private Status
Table 13.2.3 Does your organization provide export control compliance training in Orientation for Postdocs in Select Disciplines? Broken out by Carnegie class or type of college
Table 13.2.4 Does your organization provide export control compliance training in Orientation for Postdocs in Select Disciplines? Broken out by Annual Tuition
Table 13.2.5 Does your organization provide export control compliance training in Orientation for Postdocs in Select Disciplines? Broken out by Enrolment
Table 13.3.1 Does your organization provide export control compliance training in Orientation for Graduate Students in Select Disciplines?
Table 13.3.2 Does your organization provide export control compliance training in Orientation for Graduate Students in Select Disciplines? Broken out by Public/Private Status
Table 13.3.3 Does your organization provide export control compliance training in Orientation for Graduate Students in Select Disciplines? Broken out by Carnegie class or type of college
Table 13.3.4 Does your organization provide export control compliance training in Orientation for Graduate Students in Select Disciplines? Broken out by Annual Tuition
Table 13.3.5 Does your organization provide export control compliance training in Orientation for Graduate Students in Select Disciplines? Broken out by Enrolment
Table 13.4.1 Does your organization provide export control compliance training in Orientation for Undergraduates in Select Disciplines?
Table 13.4.2 Does your organization provide export control compliance training in Orientation for Undergraduates in Select Disciplines? Broken out by Public/Private Status 64
Table 13.4.3 Does your organization provide export control compliance training in Orientation for Undergraduates in Select Disciplines? Broken out by Carnegie class or type of college
Table 13.4.4 Does your organization provide export control compliance training in Orientation for Undergraduates in Select Disciplines? Broken out by Annual Tuition
Table 13.4.5 Does your organization provide export control compliance training in Orientation for Undergraduates in Select Disciplines? Broken out by Enrolment
Table 14.1 How much did the department spend in the past year on subscribing to, purchasing or developing and maintaining various vehicles for export control training? (all figures in $ US)
Table 14.2 How much did the department spend in the past year on subscribing to, purchasing or developing and maintaining various vehicles for export control training? (all figures in $ US) Broken out by Public/Private Status
Table 14.3 How much did the department spend in the past year on subscribing to, purchasing or developing and maintaining various vehicles for export control training? (all figures in $ US) Broken out by Carnegie class or type of college
Table 14.4 How much did the department spend in the past year on subscribing to, purchasing or developing and maintaining various vehicles for export control training? (all figures in $ US) Broken out by Annual Tuition
Table 14.5 How much did the department spend in the past year on subscribing to, purchasing or developing and maintaining various vehicles for export control training? (all figures in $ US) Broken out by Enrolment
RESTRICTIONS ON FOREIGN NATIONALS
What restrictions does your organization place on foreign nationals studying or working at your institution from countries subject to US export controls?
Table 15.2 Does your college or company compile periodic risk assessment reports to foresee any possible problems with export control violations before they might happen? Broken out by Public/Private Status
Table 15.3 Does your college or company compile periodic risk assessment reports to foresee any possible problems with export control violations before they might happen? Broken out by Carnegie class or type of college
Table 15.4 Does your college or company compile periodic risk assessment reports to foresee any possible problems with export control violations before they might happen? Broken out by Annual Tuition
Table 15.5 Does your college or company compile periodic risk assessment reports to foresee any possible problems with export control violations before they might happen? Broken out by Enrolment
VOLUME AND CHARACTER OF EXPORT CONTROL ACTIVITY
Table 16.1 How many Technology Control Plans has the college filed cumulatively over the past three years?
Table 16.2 How many Technology Control Plans has the college filed cumulatively over the past three years? Broken out by Public/Private Status
Table 16.3 How many Technology Control Plans has the college filed cumulatively over the past three years? Broken out by Carnegie class or type of college
Table 16.4 How many Technology Control Plans has the college filed cumulatively over the past three years? Broken out by Annual Tuition
Table 16.5 How many Technology Control Plans has the college filed cumulatively over the past three years? Broken out by Enrolment
Table 17.1 How many export control licenses has your institution applied for in the past year?
Table 17.2 How many export control licenses has your institution applied for in the past year? Broken out by Public/Private Status
Table 17.3 How many export control licenses has your institution applied for in the past year? Broken out by Carnegie class or type of college
Table 17.4 How many export control licenses has your institution applied for in the past year? Broken out by Annual Tuition
Table 17.5 How many export control licenses has your institution applied for in the past year? Broken out by Enrolment
ADVICE FOR PEERS
Which private companies, universities or other research organizations do you feel have exemplary export control policies?
What information sources -- blogs, listservs, seminars, conferences, books, websites, periodicals, etc. - have you found most useful in your work on export control compliance?
What advice can you offer to your peers in optimizing their export control regime while minimizing costs?

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